On July 28, 2010, the Securities and Exchange Commission (the “SEC”) adopted amendments to Form ADV, and related rules under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), which require advisers to deliver to clients and prospective clients a narrative brochure in plain English describing the adviser’s business practices, conflicts of interest, risks and disciplinary history. A new adviser must comply with the new form beginning January 1, 2011. An existing adviser must comply with the new form as of the date of its first annual update after January 1, 2011. For most advisers, this will be March 31, 2011. The amendments and related rule changes impact the format and content of the Firm Brochure, as well as updating and delivery requirements. In addition, the amendments create a new Brochure Supplement containing information about certain advisory personnel.

In addition, the new Firm Brochure must be written in “plain English.” All items must be presented in the order shown.

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Item 3. Table of Contents

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Item 5. Fees and Compensation

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Item 9. Disciplinary Information

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FEDERAL TAX NOTICE: Treasury Regulations require us to inform you that any federal tax advice contained herein is not intended or written to be used, and cannot be used, by any person or entity for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code.